An electric, gas, or water utility keeps three photographs: one a customer or a supervisor can match on the employee badge, one on the contractor access card, and one on the mutual-aid or visitor pass. Name the file before anyone uploads, and store an end date on every file. A state license, a passport or visa, a credential another program issues, and Form I-9 stay on the path that owns them.
Direct hires follow the HR badge guide, line and main contractors the construction guide, and agency staff the staffing guide. Contract security follows the security guide. A TWIC stays with TSA enrollment and the warehouse guide. A visa or passport follows the immigration guide. Starting from $0.20 per photo.
What does one shared photograph cost a utility?
The cost shows up at a door and at a gate. A customer cannot match the person on the step to the photo badge. A contractor is turned away because the inbox selfie is dark, or a card still opens a yard after the job has ended. One crop for the customer badge, the access card, and a storm vest puts three end dates on one file.
The U.S. Bureau of Labor Statistics counted 611.5 thousand seasonally adjusted employees in utilities (NAICS 22) in September 2026, a preliminary figure. The sector covers electric power, natural gas distribution, steam supply, and water, sewage, and other systems. It counts jobs at utility establishments. A contractor's crew is outside that figure and still needs a card from you.
| File | Who holds the camera | What goes wrong if you substitute |
|---|---|---|
| Employee badge | A link before the first day in the field, or the orientation camera. | A filtered portrait, or a contractor card reused as the badge a customer is told to check. |
| Contractor card | That assignment's template, before the person is due at the gate. | The employee's stock photo, or a card with no end date. |
| Mutual-aid or visitor pass | That event or visit's template. A staging-site camera stays for the retake. | Another utility's badge used as your access card, or a pass that still works after the crew goes home. |
| Form I-9, for people the utility employs in the United States | The employee chooses the documents. A company badge is not on the Lists of Acceptable Documents. | Filing the badge as a List A or List B document, or specifying which document to bring. |
| License, passport, visa, or another program's credential | That program's own capture. A U.S. visa follows the Department of State. A UK passport photograph meets GOV.UK photo rules. | Sending the badge crop. The board, the embassy, or HM Passport Office decides. |
The Form I-9 instructions put Section 2 within three business days of the first day, or on day one when the job is shorter. On an E-Verify case, compare the photo E-Verify displays with the document presented. Contractors complete the form with their own employer.
Which rule decides this photograph?
No single national portrait size covers a utility badge. The photograph matches a face to a record. It does not grant access or replace a background check.
On October 15, 2024, the Michigan Public Service Commission told residents to ask for a badge with photo ID and to refuse entry if it is not shown. The notice says employees are required to carry photo badges and show them when asked, and that a contractor who refuses should be refused entry. It does not set the crop, and it does not bind a utility outside Michigan. The face still has to be readable at arm's length.
In Maryland, Criminal Law §9-704 covers a badge required for employment or visitation from a covered issuer. That includes a water, sewage, gas, electric, or transmission company operating in the State, another public service company the section names, and a plant of any kind. The holder must surrender it when employment or the visit ends. A willful violation is a misdemeanor, and on conviction the person is subject to imprisonment not exceeding 90 days or a fine not exceeding $500, or both. Elsewhere, follow that state's surrender rule.
NERC lists CIP-004-7 as mandatory and subject to enforcement, and CIP-004-8 as subject to future enforcement on July 1, 2028. The standard sets no portrait size. For High Impact BES Cyber Systems and Medium Impact BES Cyber Systems with External Routable Connectivity, and their associated access-control systems, Part 3.1 confirms identity, Part 3.2 requires a seven-year criminal history records check, and Part 3.5 requires that assessment within the last seven years for people with authorized electronic or unescorted physical access. Part 2.2 requires the named training first, except during CIP Exceptional Circumstances. Table R5 Part 5.1 requires removal of unescorted physical access and Interactive Remote Access within 24 hours of a termination action. Gas distribution and water are outside it unless the company is also responsible for those systems.
Bonneville Power Administration's published request withholds limited unescorted access from other utility, contractor, and vendor workers until a background check, the required training, and a photo for badging are in. That is one transmission operator's process, not a crop size for gas or water.
How do utilities collect these photos today?
A company that has not split the files still runs on a shared inbox, a service-center printer, and a gate camera the morning someone arrives. A mutual-aid crew waits on a truck-cab retake. A contractor who finished in March can still be in the access group in June.
What does a split workflow look like?
Name the file before the first link goes out. Every file stores an end date.
1. Write down who holds the camera. Collect the employee photo before the first field day, the contractor photo before the gate time, and the mutual-aid photo before the crew rolls when you can. Keep a camera at the staging site. A public crew page, including an AI headshot, stays on that page.
2. Sort people by the record that already owns them. A direct employee gets the employee badge. A contractor gets your card through the assignment end date; that employer keeps Form I-9. Another utility's worker gets a pass that ends with the event. A visitor's pass ends with the appointment. A license, a visa, and a TWIC stay off these files. Where CIP-004-7 applies, the risk assessment and the training stay on that program.
3. Collect the file on one link, or at the utility. The badge photo service can email one link per person, with no extra account, expired after use, available per request from support@idphoto.ai. Direct hires use the employee badge page. The link does not replace a risk assessment, Form I-9, or a board application.
4. Reject a bad capture in the same visit. One person, in colour, in focus, eyes visible. Hard hats and sunglasses come off for the capture. Background removal and photo enhancement apply only when the template allows them. A visa or UK passport photograph stays unedited. See when a corrected portrait fits. A face-mask check is available per request.
5. Write the file back with its date. The utility still decides who may enter. On a replacement, face comparison checks the new capture against the stored file. Liveness detection is available per request. Take the copy back, or use a temporary link of 2 hours to 14 days. Where Table R5 applies, remove that access within 24 hours. Where Maryland §9-704 applies, collect the badge.
6. Batch one class on one template. Batch preparation returns a retake list before the print deadline. Keep new hires, one contractor company, and a mutual-aid roster in separate batches.
Many printers take ID-1 stock, nominally 85.60 mm by 53.98 mm under ISO/IEC 7810. Measure each window before the first link. A doorstep badge needs a larger face than a pass only the gate checks.
What should a utility require from a vendor?
| What you need | What good looks like |
|---|---|
| A specification per picture | Size, crop, and background for each window. See the published specifications. A license and a visa sit outside this list. |
| A block on forbidden edits | A U.S. visa photograph, and a U.S. or UK passport photograph, stay unedited. See when a corrected portrait fits. |
| Rejection in the same visit | Face, light, blur, framing, and glasses, while the person is still there. Hard hat off. A face-mask check when you ask for it. |
| A path before arrival | One link per person, no extra account, expired after use. Keep a camera for a retake, including at a staging site. |
| The record that owns the person | The file returns with its end date. Workday or SAP SuccessFactors sync is available per request for direct employees. |
| A check a gate can explain | Face comparison and liveness detection are available per request. The person at the gate still matches the face. A clean check is not an entry decision. |
How do you roll this out at one company?
Write the file rule before the first link. For one operating company, name the templates, the windows, the end dates, and which sites are in CIP-004-7 scope so the 24-hour removal sits on the right cards. A gas service center and a water plant can use the same three files without that scope.
Run one hiring class and one contractor on those templates only. The first week is two direct hires, one contractor card that ends with the order, and one same-day visitor pass. Finish a CIP-004-7 risk assessment before that card is activated, when the standard applies. One owner decides the same day who stays on the new path. Print one badge on that printer, or confirm print and mailing before you promise a card in the post. Print and mailing is available per request. Rehearse mutual aid only after that write has held.
Add the next yard after a write has held. Prove a clean upload, a retake, a walk-up, and one failed write that is retried. Open Workday or SAP SuccessFactors only for direct employees, after support confirms the connection. Do not start during a storm or a main break.
Where do these photos usually fail?
| What fails | What to change |
|---|---|
| One selfie is cropped for the customer badge, the yard card, and the outage page | Split the files. A public page needs permission that names that use. |
| A contractor card has no end date, or a visitor is in the hiring batch | Use the assignment template, or a visitor pass that ends with the appointment. |
| A card still opens a gate after the person leaves | Deactivate it the same day. Apply the 24-hour CIP-004-7 removal where that table applies, and collect the badge where Maryland §9-704 applies. |
| A lost badge is reprinted from a new truck-cab selfie | Reprint from the stored file. Retake only when face comparison fails. |
| A mutual-aid crew arrives with no usable photo | Send the link before they roll, and keep a camera at the staging site. The home utility's badge is not your access card. |
| The customer-facing photo no longer matches the person | Put a review date on the employee file. A card that still opens a door can still fail the check a resident was told to make. |
Who may see a photograph?
The employee, the people office, a supervisor, and the gate may see the file they need. A customer sees the badge at the door, not the personnel file or the risk assessment. GDPR Article 5(1)(e) and the CCPA apply where those laws apply. The data privacy policy covers encrypted transmission, a temporary link of 2 hours to 14 days, or taking the image back. US and EU processing are available. Other regions are available per request.
What do operations leads ask?
Does every utility employee need a photo badge?
The rule you operate under decides. The Michigan notice tells residents that utility employees show a photo badge when asked. A company policy can require the same badge elsewhere. CIP-004-7 does not set a portrait size. For the systems it names, it sets identity confirmation, a risk assessment, training, and removal of access.
Can the employee badge also be the contractor card?
Keep them separate. A badge ends with employment, a contractor card with the assignment, and a mutual-aid or visitor pass with the event or the appointment. Share a crop only when both windows and the purpose accept it.
Can the badge photo go on the website or an outage page?
Only with permission that names that use. A crew page is a different purpose from a card a customer checks at the door.
Can a new hire send a badge photo before the first shift?
Yes. One link, no extra account, expired after use, available per request from support@idphoto.ai. Keep a camera for a retake. Form I-9 keeps its own clock, and a CIP-004-7 risk assessment is still finished before that access.
What if the person works for a contractor or another utility?
Print your card or pass with the end date. The other employer keeps Form I-9 and its own badge. Do not treat another utility's badge as your access card. The employee template stays on your direct hires.
When should the photograph be deleted?
Delete the file on the date stored with it, and deactivate the card the day the person leaves. Where CIP-004-7 Table R5 applies, remove that access within 24 hours of the termination action. Where Maryland §9-704 applies, the person surrenders the badge. GDPR Article 5(1)(e) keeps personal data in the UK and the EU no longer than necessary.
What does preparing the photograph cost?
It starts at $0.20 per photo. That is separate from a printer lease, a background check, and a government fee. The catalog covers 300+ specifications across 200+ countries.
How does idphoto.ai fit this workflow?
The idphoto.ai API is the photo step. It prepares a portrait to the template you name, checks the capture, and returns a file for the employee record, the contractor record, or the printer. The utility decides who receives a card and which gate it opens. Form I-9, a license, a TWIC, and a visa stay on their own path. A UK passport photograph must meet GOV.UK photo rules. A UK passport photo code retrieves a photograph that meets those rules, and HM Passport Office still decides. The catalog covers 300+ specifications across 200+ countries, starting from $0.20 per photo.
Templates, the self-service link, Workday or SAP SuccessFactors sync, print and mailing, liveness detection, a face-mask check, another processing region, and the Shopify store template with one-click setup are each available per request. The store stays off the access record. Email support@idphoto.ai with the card designs, which sites are in CIP scope, the end dates, and how the file returns.